Use Form 8594.

Target Corporations assets are acquired by Acquiring Corporation in exchange for $2,600,000 of cash to be paid to Target Corporation. The purchase agreement is dated October 6, 2016.

Target Corporations EIN is 23-372698674. Target Corporations address is 3245 Industrial Blvd., Albuquerque, 87103. YOU REPRESENT TARGET (THE SELLER) AND WILL REPORT THE FORM ON BEHALF OF THE SELLER.

Acquiring Corporations EIN is 23-900653890. Acquiring Corporations address is 9200 Bretton Lakes Rd., Nashville, TN, 37209.

The contract lists the following assets and values assigned by the parties. The parties have agreed that they will follow the purchase price allocation as stated in the contract.

Asset	Assigned FMV
Cash	55,000
Inventory	310,000
Accounts Receivable	155,000
Workforce in Place	120,000
Customer Lists	60,000
Copyrights	80,000
Equipment	225,000
Furnishings	85,000
Land	240,000
Building	860,000

In addition to the $2,600,000 paid to Target Corporation, Acquiring has also entered into a covenant not to compete with Jack Sparrow, the President of Target. Sparrow will be paid $400,000 for an agreement to not compete with Acquiring for a period of 30 months after the acquisition.

8594 Asset Acquisition Statement OMB No. 1545-1021 Under Section 1060 (Rev. December 2012) Attach to your income tax return Attachment Intema Revenue Service nformation about Form 8594 and its separate instructions at Sequence No. 169 www oviform 8594 Name as shown on return Identifying number as shown on return Check the box that identifies you Purchase Seller Part General Information 1 Name of other party to the transaction other party's identifying number Address (number, street, and room or suite no.) City or town, state, and ZIP code 2 Date of sale 3 Total sales price (consideration) nal Statement of Assets Transferred Assets Aggregate fair market value (actual amount for Class l) Allocation of sales price Class I Class II Class III Class V Class M and VII Total 5 Did the purchaser and seller provide for an allocation of t he sales price in the sales contract or written document signed by both parties? another If "Yes," are the aggregate fair market values listed for each of asset classes l, ll, lll, IV, V. V, and VI the amounts agreed upon in your sales contract or in a separate written document? 6 In the purchase of the group of assets (or stock) did the purchaser also purchase a license or a covenant not to compete, or enter into a lease agreement, employment contract, management contract, or similar arrangement with the seller (or managers, directors, owners, or employees of the seller)? If "Yes," attach a statement that specifies (a) the type of agreement and (b) the maximum amount of consideration (not including interest) paid or to be paid under the agreement. See instructions. For Paperwork Reduction Act Notice, see separate instructions. Cat, No. 63768Z Form 8594 (Rev. 12.20 NO Te